Texas Proposes No Exemptions in Rabies Rules

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Unless there is strong opposition,Texas Department of Health Services will make changes in rabies control and prevention laws that have unintended consequences to animals, pet owners, animal lovers and veterinary professionals alike.

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Texas pet owners and animal lovers nationwide who support rabies medical exemption for sick and senior pets are urged to respond to proposed changes to laws covered in TAC 169.21 - 169.34 pertaining to the control and prevention of rabies. These were published for public comment in the Texas Register on August 31, 2007. The comment period runs until September 30, 2007.

Petition for reasonable reform

In August, Bob Rogers, DVM of Houston, who is nationally recognized for his efforts to reform outdated rabies laws and Pamela Picard, a Texas resident and advocate for rabies medical exemption, presented a petition to the Texas Department of Health Services (TDHS) Council, which is responsible to review rabies laws every four years. The petition which is still open for signatures urges a provision to allow veterinary discretion in revaccinating dogs and cats when they are unhealthy or aged. A legion of animal lovers of every stripe as well as concerned veterinary professionals endorses rabies medical exemption.

"Any pet that has had at least two rabies vaccinations in its lifetime is at very minimal risk of developing rabies, and it is unlikely that this patient will benefit from another vaccination," wrote Dr. Bob Rogers in a letter sent ahead of the public meeting to Dr. Tom Sidwa, Texas State Public Health Veterinarian. "Veterinarians should have discretion in assessing the risk of the pet being exposed to rabies vs. the risk of an adverse and potentially fatal reaction.

Despite scientific evidence and strong public support, TDHS proposes no allowance for domestic animals that are being treated by a licensed veterinarian for acute or chronic illnesses or have a history of adverse reactions from the rabies vaccine.    

No safety and efficacy standards

Instead, TDHS proposes to gut language that advises veterinary professionals to follow the safety and efficacy standards on the vaccine manufacturer's label which state "for use in healthy animals."

Proponents of rabies medical exemption believe that deleting this language is ill advised.

Administering rabies vaccine when an animal is pregnant, stressed, undergoing surgery, in an emergency or in treatment for illness can cause unpredictable reactions and death. Even a slight elevation in an animal's body temperature can thwart the drug's efficacy.

No medical benefit for animals

Repeat rabies shots have no medical benefit The practice of re-vaccination at one or three-year intervals is purely based on precedent.

In a landmark report on vaccines published in 2002 by the AVMA Council on Biologic and Therapeutic Agents (COBTA) stated that there is no scientific basis for annual revaccination. Re-administering rabies vaccine does not enhance disease resistance and may expose animals to unnecessary risk.

Unnecessary risk to animal health

Veterinary researchers have associated rabies vaccine with Vaccine Associated Sarcoma (VAS,) Immune Mediated Hemolytic Anemia (IMHA) and Immune Mediated Thrombocytopenia (IMT,) all life-threatening dysfunction. Prognosis is guarded. Treatment is expensive.

"After two VAS cats and $25,000, I think vaccines suck." says Kris Hanson, a pet owner who provided testimony to enact rabies medical exemption in Connecticut. "How's that for this so called 'very rare VAS?' I had four cats and two had VAS; that's 50 percent in my house alone."

Other chronic health concerns such as allergies, asthma, arthritis, ear infections, thyroid disease, heart disease, kidney failure and cancer are also believed to develop after too many vaccinations.

Potential health concerns aside, licensing language in the proposed rabies rules may cause the needless destruction of well-immunized dogs and cats.

All dogs and cats at risk

As written, any animal that is overdue for rabies re-vaccination by a week or month (according to the interval of the drug the veterinarian recommends) would be deemed "unvaccinated" because it has not been revaccinated before the interval lapses. An "unvaccinated" dog or cat - including a service or therapy dog - that is involved in a bite incident or suspected of rabies exposure must be isolated at the owner's expense or it is destroyed.

"When a Texas motorist driving on an expired license is involved in a traffic mishap, he gets a ticket and pays a fine," Pamela Picard says. "When a dog or cat is suspected of rabies exposure, even if it's had 10 rabies shots in its life, it gets hard time or it goes to heaven."

Immunity does not expire

To be perfectly clear: the duration of a license may expire; a dog or cat's immunity to rabies does not expire in one or three years.

Serological studies done by Dr. Ronald Schultz, Professor and Chair, Patho-biological Sciences, the University of Wisconsin School of Veterinary Medicine over the course or 30 years show that dogs have antibody titer counts at levels that confer immunity to rabies seven years after one vaccination.

No change in compliance

TDHS defends its proposed revisions, stating that this is the best way to protect animals and the public against rabies. Advocates for rabies medical exemption question this statement.

In 2002, Texas Department of Health Services Zoonosis Division reported that only 50 percent of dog owners and 25 percent of cat owners vaccinated against rabies. When 22 veterinary schools and top veterinary professional associations endorsed it, the Texas legislature amended rabies rules in 2003 to extend the interval between rabies boosters.

"To the best of our knowledge, four years down the road, there are twice as many dogs and cats in Texas, canine rabies has been eradicated and compulsory rabies vaccinations have not improved compliance." says Ms. Picard. "Rabies laws penalize responsible, law-abiding citizens."

Currently, rabies medical exemption is permitted in California, Connecticut, Florida, New Jersey, New York and Maine. It does not exempt the owner of a dog or cat from buying city or county licenses. Instead, it gives responsible dog and cat owners a reasonable way to obey the law as well as protect the health of family pets, show dogs and cats, hunting dogs, shelter rescues and all domestic animals in their care.

These were among the first of 34 states to amend rabies prevention and control laws to extend the interval between rabies shots to three years; Texas was the last.

Comments on the proposal must be submitted in writing to Tom Sidwa, DVM, Department of State Health Services, Community Preparedness Section, Zoonosis Control Branch, P. O. Box 149347, Austin, Texas 78714-9347. You do not have to be a Texas resident to comment.


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Pamela Picard

Bob Rogers DVM
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